Money Laundering Reporting Officer (MLRO) - UAEKey Responsibilities Governance, Strategy & Risk Management AML/CFT Program Ownership: Develop, implement, manage, and continuously update the comprehensive AML/CFT program, policies, and procedures, ensuring specific controls for Virtual Asset transfers, wallet management, and cross-chain transactions. Risk Assessment: Conduct and periodically refresh the firm’s comprehensive Institutional Risk Assessment (IRA), specifically identifying, measuring, and mitigating Money Laundering (ML) and Terrorist Financing (TF) risks associated with new virtual asset listings, decentralised protocols, and emerging financial crime typologies. Senior Management Reporting: Prepare and submit semi-annual MLRO reports to the Board/Senior Management, detailing the efficacy of the AML/CFT program, identifying deficiencies, and recommending clear remediation steps with deadlines. Regulatory Adherence: Ensure strict adherence to the Travel Rule requirements for Virtual Asset transfers, implementing technical solutions for information exchange with counterparty institutions.Regulatory & Reporting Obligations Financial Intelligence Unit (FIU) Liaison: Serve as the designated point of contact for the UAE FIU, mandatory registration and utilization of the go AML platform for all required reporting. Suspicious Reporting (VA Focused): Receive, review, scrutinize, and analyze all internal Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) related to Virtual Asset transfers. This includes analyzing complex on-chain activity patterns and utilizing external analysis for decision-making. Mandatory Reporting: Oversee the timely submission of all mandatory reports via go AML, including STRs/SARs, Fund Freeze Reports (FFR), Partial Name Match Reports (PNMR), and High-Risk Country Reports (HRC). Regulatory Communication: Handle all communication, inquiries, and requests for information from the Supervisory Authority (e.g., VARA, CBUAE, DFSA, FSRA) and law enforcement agencies concerning digital asset investigations. Sanctions Compliance: Ensure immediate compliance with targeted financial sanctions regimes, conducting wallet address screening and executing freezing without delay on funds or assets belonging to sanctioned individuals or entities.Operations & Control Virtual Asset Due Diligence (VADD): Oversee the effective implementation of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) processes, specifically addressing the source of funds/wealth in Virtual Assets and the risk profiling of private wallets and counterparties. Know Your Transaction (KYT) Monitoring: Maintain and optimize the KYT system, utilizing blockchain analytics to monitor transaction flows, flag high-risk clusters (e.g., mixers, darknets, illicit addresses), and ensure alert parameters are effective in detecting unusual activity. Record-Keeping: Ensure all required documentation relating to CDD, on-chain investigation logs, transactions, compliance monitoring, and reporting is maintained and readily retrievable for the minimum statutory period (currently five years). Training: Design, execute, and document ongoing AML/CFT training that includes specific modules on Virtual Asset risk indicators, blockchain analysis tools, and VASP regulatory obligations.Audit & Review Internal Audit: Coordinate and facilitate independent internal and external audits of the AML/CFT program, ensuring specific scrutiny of Virtual Asset controls and prompt implementation of corrective actions for all deficiencies.Who We Are Looking For Core Competencies:Independence & Authority: The proven ability to act independently and exercise authority necessary to ensure regulatory compliance, even if contrary to the commercial interests of the firm. Judgment: Exceptional analytical, investigative, and decision-making skills, with the ability to exercise sound judgment in complex virtual asset financial crime scenarios. Communication: Fluent English is mandatory; fluency in Arabic is highly beneficial. Must possess superior report-writing and presentation skills for communication with the Board and regulators. Leadership: Demonstrated leadership and management capabilities to oversee a compliance team and foster a strong culture of compliance across the organization.Required Experience:5-10 years of progressive experience in AML/CFT compliance, financial crime prevention, or risk management, with at least 3 years specifically within the Virtual Asset/Crypto industry. Mandatory UAE Experience: Demonstrated experience operating as an MLRO, Head of Compliance, or Deputy MLRO within the UAE or one of its Financial Free Zones (DIFC, ADGM), with experience adhering to VARA or equivalent DLT regulations. Deep practical knowledge of Federal Decree-Law No. 20 of 2018 and its Implementing Regulations, FATF Recommendations (specifically Recommendation 15 on VASPs), and relevant local DLT/VA frameworks. Essential Technical Skill: Proven proficiency and hands-on experience using industry-standard blockchain analytics tools (e.g., Chainalysis, Elliptic, TRM, etc.) for on-chain investigations and risk scoring. Bachelor's degree in Law, Finance, or a related field. Mandatory Certification: Possession of a globally recognized certification, such as Certified Anti-Money Laundering Specialist (CAMS) or Certified Cryptocurrency Investigator (CCI) is highly preferred.